Articles

Taxpayers Not Allowed to Revoke Tax Elections Based on Later Change in Regulation Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on e...

On September 29, 2021 Senator Richard Burr (R-NC) introduced legislation that would cause student-athletes to pay federal income tax on athletic scholarships if those student-athletes earn more than $20,000 in receipts from monetizing their name, ima...

Those wishing to sell and diversify highly appreciated assets (stocks, real estate) and those who have lots of taxable income should consider a charitable remainder trust (“CRT”) to minimize income tax on capital gains as well as gift and estate tax....

Nonprofit charities regularly own or receive donations of real estate. In the real estate world, holding title to property in an isolated limited liability company is so common that many lenders’ and brokers’ template forms refer to “______ LLC,” wit...

When attempting to exchange a business, exchanging the goodwill component is often a dead end. Goodwill of two different businesses may never be of like kind. Treas Reg § 1.1031(a)-2(c)(2). Goodwill associated with real estate, however, can generally...

It is often assumed that if a taxpayer receives cash in a tax-free exchange, the cash must be boot. It can be quite frustrating when a replacement property-lender requires that reserves be funded at closing, and funding those reserves with cash crea...